U.S. Department of Homeland Security
Immigration and Customs Enforcement
Office of Professional Responsibility
Inspections and Detention Oversight Division
Washington, DC 20536-5501

Office of Detention Oversight
Compliance Inspection
Enforcement and Removal Operations
ERO San Antonio Field Office
Laredo Processing Center
Laredo, Texas

July 14–16, 2015

 

COMPLIANCE INSPECTION
for the
LAREDO PROCESSING CENTER
LAREDO, TEXAS
TABLE OF CONTENTS

EXECUTIVE SUMMARY
Overall Findings...................................................................................................................2
Findings by National Detention Standard (NDS) 2000 Major Categories ..........................3
INSPECTION PROCESS .............................................................................................................4
DETAINEE RELATIONS ............................................................................................................5
INSPECTION FINDINGS
DETAINEE SERVICES
Detainee Grievance Procedures ...........................................................................................6
Staff-Detainee Procedures ...................................................................................................6

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INSPECTION TEAM MEMBERS

(b)(6), (b)(7)c

Office of Detention Oversight
July 2015
OPR 201507396

Lead Inspections and Compliance Specialist ODO
Inspections and Compliance Specialist
ODO
Contractor
Creative Corrections
Contractor
Creative Corrections
Contractor
Creative Corrections
Contractor
Creative Corrections
1

Laredo Processing Center
ERO San Antonio

 

EXECUTIVE SUMMARY
The Office of Detention Oversight (ODO) conducted a compliance inspection of the Laredo
Processing Center (LPC) in Laredo, Texas, from July 14 to 16, 2015. 1 LPC opened in 1985 and
is owned and operated by the Corrections Corporation of America (CCA). Enforcement and
Removal Operations (ERO) began housing detainees at FDC in 1985 pursuant to an
Intergovernmental Service Agreement (IGSA), under the oversight of ERO’s Field Office
Director (FOD) in San Antonio, Texas.
ERO staff members are assigned to
Quantity
the facility. A Detention Services Capacity and Population Statistics
Manager is not assigned to the ICE Detainee Bed Capacity2
400
facility.
A CCA Warden is Average ICE Detainee Population3
263
responsible for oversight of daily
Male Detainee Population (as of 07/14/2015)
0
facility operations and is supported
310
by (b)(7)e personnel.
Trinity Food Female Detainee Population (as of 07/14/15)
Service provides food services, and CCA provides medical care at the facility. The facility holds
no accreditations. The facility is not contractually obligated to comply with ICE PerformanceBased National Detention Standards (PBNDS) 2011, Sexual Abuse and Assault Prevention and
Intervention (SAAPI) standard but made efforts to comply.4

OVERALL FINDINGS
In April 2009, ODO (at the time
Detention
Facilities
Inspection
Group) conducted an inspection of
LPC under the National Detention
Standards (NDS) 2000, reviewing
the facility’s compliance with 15
standards and finding LPC compliant
with 13 standards. There were a
total of two deficiencies in the
remaining two standards.

Inspection Results
Compared

FY 2009
(NDS 2000)

FY2015
(NDS 2000)

Standards Reviewed

15

15

Deficient Standards
Overall Number of
Deficiencies

2

2

2

2

Corrective Actions Initiated
Deficient Priority
Components

0

1

N/A

N/A

In FY2015, ODO conducted an inspection of LPC under the NDS 2000, reviewing the facility’s
compliance with 15 standards and finding the facility compliant with 13 standards. ODO found
two deficiencies under the remaining two standards. Finally, ODO identified one opportunity
where the facility initiated corrective action during the course of the inspection.5

                                                            
1

 Female detainees with low, medium and high security classification levels are detained at the facility for longer
than 72 hours.
2
 Data Source: ERO Facility List Report as of July 6, 2015 
3
 Ibid. 
4
 The facility has a stated zero tolerance policy and has appointed a Prison Rape Elimination Act (PREA)
compliance manager. The facility has a Sexual Abuse Prevention and Response policy and a program for
complying with PREA requirements. All staff members and contractors receive facility-provided PREA training.
5
Corrective actions, where immediately implemented, best practices and ODO recommendations, as applicable,
have been identified in the Inspection Findings section and annotated with a “C”, “BP” or “R”, respectively.

Office of Detention Oversight
July 2015
OPR 201507396

2

Laredo Processing Center
ERO San Antonio

 

FINDINGS BY NDS 2000 MAJOR CATEGORIES
NDS 2000 STANDARDS INSPECTED6

DEFICIENCIES

Part 1 – Detainee Services
Access to Legal Material
Admission and Release
Detainee Classification System
Detainee Grievance Procedures
Detainee Handbook
Food Service
Funds and Personal Property
Staff-Detainee Communication
Telephone Access
Sub-Total

0
0
0
1
0
0
0
1
0
2

Part 2 – Security and Control
Environmental Health and Safety
Special Management Unit (Administrative)
Special Management Unit (Disciplinary)
Use of Force
Sub-Total

0
0
0
0
0

Part 3 – Health Services
Medical Care
Suicide Prevention and Intervention
Sub-Total

0
0
0

Total Deficiencies

2

                                                            
6

For greater detail on ODO’s findings, see the Inspection Findings section of this report.

Office of Detention Oversight
July 2015
OPR 201507396

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Laredo Processing Center
ERO San Antonio

 

INSPECTION PROCESS
Every fiscal year, the Office of Detention Oversight (ODO), a unit within U.S. Immigration and
Customs Enforcement’s (ICE) Office of Professional Responsibility (OPR), conducts
compliance inspections at detention facilities in which detainees are accommodated for periods
in excess of 72 hours and with an average daily population greater than ten to determine
compliance with the applicable ICE National Detention Standards (NDS) 2000, the PerformanceBased National Detention Standards (PBNDS) 2008 or 2011.
During the compliance inspection, ODO reviews each facility’s compliance with those detention
standards that directly affect detainee health, safety, and/or well-being.7 Any violation of written
policy specifically linked to ICE detention standards, ICE policies, or operational procedures that
ODO identifies is noted as a deficiency. ODO will highlight any deficiencies found involving
those standards that ICE has designated with either the PBNDS 2008 or 2011 to be “priority
components.” 8 Priority components have been selected from across a range of detention
standards based on critical importance, given their impact on facility security and/or the health
and safety, legal rights, and quality of life of detainees in ICE custody.
Immediately following an inspection, ODO hosts a closeout briefing in person with both facility
and ERO field office management to discuss their preliminary findings, which are summarized
and provided to ERO in a preliminary findings report. Thereafter, ODO provides ERO with a
final compliance inspection report to: (i) assist ERO in working with the facility to develop a
corrective action plan to resolve identified deficiencies; and (ii) provide senior ICE and ERO
leadership with an independent assessment of the overall state of ICE detention facilities. The
reports enable senior agency leadership to make decisions on the most appropriate actions for
individual detention facilities nationwide.

                                                            
7
8

ODO reviews the facility’s compliance with selected standards in their entirety.
Priority components have not been identified for the NDS.

Office of Detention Oversight
July 2015
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Laredo Processing Center
ERO San Antonio

 

DETAINEE RELATIONS
ODO interviewed 30 detainees, who volunteered to participate. None of the detainees made
allegations of mistreatment, abuse, or discrimination. The majority of detainees reported being
satisfied with facility services, with the exception of the complaints below:


Food Service: Ten detainees alleged food is served cold or raw and is not rotated.
o



Action Taken: ODO measured the temperature of the food during lunch service
and determined the meals were served at the appropriate temperatures. The food
service staff notified ODO that the facility has a certified meal rotation schedule
in place.

Telephone Access: Two detainees alleged they do not have access to the telephones.
o

Action Taken: ODO reviewed the detainee handbook, which reveals detainees
must purchase a calling card through commissary or detainees can make collect
calls without a calling card. ERO staff discussed the use of the phones and calling
cards with the detainees.

Office of Detention Oversight
July 2015
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Laredo Processing Center
ERO San Antonio

 

INSPECTION FINDINGS
DETAINEE SERVICES
DETAINEE GRIEVANCE PROCEDURES (DGP)
ODO reviewed facility policy and confirmed in interviews with facility staff the facility does not
have a grievance committee to review a formal written grievance (Deficiency DGP-19).
Corrective Action:
The facility initiated corrective action by creating a grievance
committee consisting of the Grievance Coordinator, a Security Staff representative, and
an ERO representative. A memorandum of the information was posted in the detainee
housing units (C-1).
STAFF-DETAINEE COMMUNICATION (SDC)
ODO reviewed 30 requests from April 2015 to July 2015 and verified that requests were
responded to within 72 hours, but determined through review of associated detention files and
interviews of knowledgeable facility staff at least ten of the completed detainee requests were not
filed in the detainee’s detention file and maintained for at least three years (Deficiency SDC110).

                                                            
9

“The OIC must allow the detainee to submit a formal, written grievance to the facility’s grievance committee.”
See ICE NDS 2000, Standard, Detainee Grievance Procedures, Section (III)(A)(2).
10
“All completed Detainee Requests will be filed in the detainee’s detention file and will remain in detainee’s
detention file for at least three years.” See ICE NDS 2000, Standard, Staff-Detainee Communication, Section
(III)(B)(2).

Office of Detention Oversight
July 2015
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6

Laredo Processing Center
ERO San Antonio